EPC Response to the European Commission Green Paper, 'Towards an Integrated European Market for Card, Internet and Mobile Payments

27 April 2012

In its response, the European Payments Council outlines key policy considerations which, in its view, should be observed when determining the need for EU action to address 'gaps' perceived by the Commission with regard to competition, choice, innovation and other 'market integration drivers'.

In January 2012, the European Commission (the Commission) published its Green Paper, ‘Towards an integrated European market for card, internet and mobile payments’ for a three month consultation. The aim of the Green Paper, according to the Commission, is to identify the obstacles that potentially prevent integration in this area. The Commission stated that the contributions to the consultation will determine the need for European Union (EU) action on the various issues raised in the Green Paper and the form this action should take.

The EPC does not support a number of related assumptions and suggestions put forth in the Green Paper. Consequently, the EPC believes that many of those suggestions will not help achieve the stated objectives and may even undermine their realisation. A thorough factual analysis of the EU payment landscape is however a prerequisite for any conclusion that further regulatory action may be required. This analysis should recognise the following market realities:

• Europe is not a fully integrated market in terms of economic development, cultural background, customer preferences or regulatory framework.
• Europe and its payment markets cannot be considered in isolation as they are part of an increasingly integrated global economy.
• Payments do not act as a main barrier to the development of e-commerce otherwise e-commerce would not have experienced continuous fast growth as evidenced by several market studies.

The EPC regrets that the Green Paper seems to overlook major market achievements to date to progress the Single Euro Payments Area (SEPA).

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